Sierra Forest Legacy Newsletter

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The Sierra Forest Voice Newsletter

The Sierra Forest Voice

Web Edition
Vol. 12, No. 2, June 25, 2019


Prescribed Burn Associations: Restoring Fire and Building Community on California's Private Lands

Tahoe NF showing land ownership Like any basic ecological process, fire doesn’t pay much attention to property boundaries. Most of the larger headline-making wildfires of the past decade have burned through a mix of public and private lands, contributing to mixed fire behavior and fire effects. Though conservation groups including SFL have long focused the vast majority of our efforts on public lands, the need for an “all lands” approach to restoration becomes more apparent each fire season. New grassroots prescribed burn associations (PBAs) led by landowners hold promise for making prescribed fire a viable management tool for private landowners. Having recently taken hold in California, PBAs are quickly proving that by building community knowledge and enthusiasm around burning, we can increase our collective ability to accept fire as an inevitable, natural, and critical part of our landscape.

Image above: This clip of the Tahoe National Forest forest map illustrates the checkerboard ownership of much of the Sierra Nevada, where every other square mile of publicly owned lands (green) is a privately owned parcel (white)l. Much of these parcels are owned by timber companies and are managed as industrial timberlands. Learn about the history of how this checkerboard ownership pattern came to be here.

According to a 2017 study from the Public Policy Institute of California, non-industrial forested parcels less than 5,000 acres make up nearly 25 percent of the headwater forests of the Sierra Nevada and southern Cascades. For many of these landowners, prescribed fire may not seem like a realistic option for improving forest health on their land due to a variety of perceived barriers including liability concerns, limited burn windows, permitting, lack of equipment, and lack of training. Private landowners who wish to burn, but don’t have a background in prescribed fire must either hire a professional contractor (often not financially viable for smaller landowners), or enter an agreement with Cal Fire’s Vegetation Management Program (VMP), which has limited capacity to implement burns during good burn windows. Indeed, the VMP has generally burned fewer than 10,000 acres per year statewide over the past decade.

Prescribed burn associations offer a promising third option for landowners seeking to burn. The concept is simple: landowners volunteer their time and resources to help each other through organized collaborative burning clubs. PBAs are able to get valuable assistance from local volunteer fire departments, which use the community burns as much-needed training opportunities. By organizing into a formal group, PBAs are able to share tools, apply for grants, and pursue liability protections not available to individual landowners.

Map of prescribed burn associations in TX, OK, and KSPBAs have long been popular in the middle and midwestern states, where prescribed fire is a popular tool for improving rangelands and wildlife habitat in grassland environments (see image left).

In 2017, a group of landowners and fire professionals in Humboldt County decided to bring the model to California after participating in several PBA-led burns in Nebraska. The group began by holding several workshops and collaborating on a series of small training burns, before formalizing as the Humboldt County Prescribed Burn Association–the first PBA in the west–in 2018. Since then, the Humboldt PBA has acquired a community prescribed fire equipment trailer, developed a list of priority projects totaling more than 2,200 acres, and burned hundreds of acres in multiple northwestern CA fuel types.

The social effect of the Humboldt PBA’s success has been striking. Because landowners must volunteer their time on other projects in order to get their properties onto the PBA’s projects list, the burns have increased the Humboldt community’s knowledge around prescribed fire among nonprofessionals. This has made future burns easier to implement, while also building trust within McBride Prescribed Burn Humboldt COthe community. At this year’s Northern California Prescribed Fire Council, the PBA organizers also noted a substantial increase in Humboldt County landowners’ interest in burning. More landowners have contacted the PBA about burning their own properties after seeing their neighbors successfully use prescribed fire with good results. On top of this, the PBA also provides an easy go-to organization to help landowners navigate restrictions around air quality regulations and Cal Fire permitting when good burn windows appear.

Image left: McBride Burn, recently completed by the Humboldt County Prescribed Burn Association.

At least four other California counties are currently working to form PBAs, including three in the Sierra Nevada. In Plumas County, the Plumas Underburn Cooperative recently completed two pile burn projects and has plans to expand to broadcast burning in the future. The Butte County Resource Conservation District recently received a grant from the Department of Conservation, which includes funding to organize a PBA.

Sierra Forest Legacy recently began working alongside University of California Cooperative Extension to help kick-start a PBA in western Nevada County. The Nevada County group met for the first time in early June to plan several community training opportunities for the summer and fall of 2019. We hope that building a community of fire users in the Sierra will help increase the pace and scale of fire use across all ownerships.

For more information about the Nevada County Prescribed Burn Association, please contact Jamie Ervin at

  Spring 2019 State Fire Policy Update

In the wake of the most destructive fire season in California’s history, the California legislature has been hard at work improving our state’s policies and capacity around managing fires. The article below summarizes five recent bills, all of which successfully passed through their respective chambers of origin with bipartisan support in May 2019. Each bill takes a different angle for making our communities safe and resilient. Sierra Forest Legacy supports all five of these bills and urges Governor Newsom to sign them into law if and when they make it to his desk.

Senate Bill 462 (Stern) – Restoration Workforce: The capacity to implement restoration activities like prescribed burning—meaning the availability of a well-trained workforce—is one of the primary barriers to creating resilient landscapes in California. SB 462 would improve our state’s capacity around restoration in two ways: (1) the bill creates a model community college curriculum around forest restoration in California, and (2) the bill expands the University of California Cooperative Extension Fire Advisors Program to assign a fire advisor to every county in the state. Encouragingly, the text of SB 462 specifically calls out the surface and ladder fuels that drive fire behavior in California’s frequent-fire forests. If passed, students in certain California community colleges would have the option of enrolling in a forestland restoration program by the 2021/2022 academic year. Click here to read Sierra Forest Legacy’s letter in support of SB 462.

Assembly Bill 1668 (Carillo) – CA Conservation Corps Education and Employment Reentry: Like SB 462, AB 1668 would improve California’s capacity for forest restoration by investing in a sustainable workforce. The bill would provide a pathway for formerly incarcerated individuals to gain stable employment with the CA Conservation Corps through a newly-formed Education and Employment Reentry Program. Many inmates already gain experience serving with fire suppression hand crews while incarcerated through the existing Conservation Camp Program. AB 1668 would help these individuals find gainful employment post-release, while also raising California’s capacity to treat a larger portion of the landscape.

Senate Bill 182 (Jackson) – Local Government Planning and Zoning for Wildfires: Shortly before retiring in late 2018, Cal Fire Chief Ken Pimlott called on the state to consider limiting home construction in fire prone areas. SB 182 appears to answer Chief Pimlott’s call by increasing the planning and zoning requirements around construction in Very High Fire Hazard Severity Zones (Cal Fire’s classification for areas with the highest fire risk). More specifically, this sweeping bill would:

  • Require local governments to amend their general plans to incorporate recent state guidance for development in high fire risk areas (which are expanded under the bill)
  • Require counties to develop a retrofit strategy in their general plans for structures that are vulnerable to wildfire
  • Requires local governments to prove that they are complying with defensible space, vegetation management, and local wildfire hazard mitigation plans
  • Defines wildfire risk reduction standards for future developments, and prohibits cities and counties from approving certain types of development in Very High Fire Hazard Severity Zones that do not meet these standards

Assembly Bill 1516 (Friedman): Defensible Space and Fuels Management: Vegetation within the immediate vicinity of a structure is an important factor contributing to home ignitions in wildland-urban interface fires. AB 1516 would strengthen California’s defensible space requirements by requiring a five foot non-combustible zone around structures in the State Responsibility Area or in Very High Fire Hazard Severity Zones. Local governments would be charged with inspecting defensible space within their communities and reporting inspections and enforcement actions back to Cal Fire. The bill also places additional requirements for vegetation clearing around powerlines, and requires that Cal Fire make their fuel crews available for defensible space clearing projects where possible.

Assembly Bill 38 (Wood): Low Cost Retrofits for Fire Hardened Homes: While AB 1516 focuses attention on the vegetation immediately surrounding structures, AB 38 seeks to make structures themselves more resilient to wildfire. Retrofits to homes like dual-paned windows, fire-resistant vents, ignition-resistant roofs, and enclosed gutters can all prevent structures from igniting during wildfires. However, many homeowners are slow to adopt these retrofits, or unable to afford them entirely. AB 38 would address this issue by requiring the seller of a building in a Very High Fire Hazard Severity Zone after July 2025 to make low-cost retrofits identified by Cal Fire prior to sale. To help pay for these retrofits, the bill creates a revolving loan and rebate fund which would issue low or no-interest loans to homeowners. Finally, the bill requires the California Natural Resources Agency  to review the capacity of each county with high fire risk areas to undertake future fire prevention activities. The results of the agency’s review are intended to identify capacity gaps and to help prioritize particular areas for grant opportunities.

U.S. Forest Service California Spotted Owl Conservation Strategy: the Agency Recommends Greater Risk and Less Conservation for this Declining Species

The U.S. Forest Service has released the long awaited Conservation Strategy for the California Spotted Owl in the Sierra Nevada. Development of the strategy was internal to the agency and authorship of the document is not identified. We commented The strategy states that the primary threats to the species are high severity fire, climate change, and competition with nonnative invasive barred owls. Despite the well documented dependence of this species on older forests dominated by higher densities of medium and larger trees,  the authors claim that the threat posed by logging of these trees is unclear. The strategy goes on to suggest that trade-offs between management impacts and long-term habitat sustainability must be made, but provides no scientific evidence that the habitat conditions it describes will support thriving spotted owl populations.   

From our initial review of the new strategy, we have identified the following significant changes to current forest management practices that are likely to exacerbate ongoing population declines:

The amount of protected nesting and roosting habitat is reduced.
Areas where higher densities of larger trees must be maintained for nesting and roosting, i.e., 300-acre Protected Activity Centers (PACs), will only be designated for territorial male-female pairs. Existing standards and guidelines require that PACs be designated for territorial individuals, as well as pairs. This change will drastically reduce the amount of nesting and roosting habitat protected for this species. No rationale has been provided to support this change.

Protections for nesting and roosting habitat would be removed after three years for some territorial individuals.
PACs will be removed from the system after 3 years of surveys if the PAC is not found to be occupied by a pair during the surveys. The current standard is to maintain all designated PACs as long a sufficient amount of nesting and roosting habitat is provided. No information on the probability of a PAC occupied by a single becoming occupied by a pair was provided, or any other justification for the specific change in management direction.

Logging that degrades habitat conditions is allowed in “protected” nesting and roosting habitat.
One-third of each PAC may now be mechanically logged in a manner that reduces habitat quality. Several ambiguous limits to this allowance are provided in the strategy; therefore, it remains unclear the level of effect this change will have on the species. Except when PACs occur adjacent to communities, current guidance requires that mechanical treatments may only occur in PACs where prescribed fire is not feasible and treatments must be designed to maintain the structure and function of the PAC. 

The strategy promotes habitat conditions that are likely to reduce survival and reproduction and increase territory abandonment of nest stands.
The new strategy replaces the Home Range Core Area (HRCA) designation with a territory designation, drastically reducing the amount of habitat managed for spotted owl nesting, roosting, and foraging outside of each PAC. For example, the reduction of habitat protection afforded moderate and higher canopy cover nesting, roosting, and foraging habitat outside of PACs in the new strategy would be 84% lower in the central Sierra, dropping from 700 acres to a minimum of 100 acres. In addition to the changes in acreage thresholds, the management recommendations in the new strategy for the territory-designated habitat are unclear and we are concerned that what is recommended would provide for lower quality habitat than HRCAs. No science information was provided in the strategy or related materials justifying that the amount and quality of habitat included in the territory designation will support stable reproduction, survival, or occupancy.

Disturbance to breeding spotted owls is allowed.
The new strategy now allows the Limited Operating Periods (LOP) for activities known to disturb breeding spotted owls (e.g., chainsaws and logging equipment near nest stands) to be to be waived, but provide little guidance on when such a waiver is appropriate. This is concerning because disturbances are known to cause nest failures and nest failures are associated with loss of occupancy--and loss of occupancy could also result in the loss of PAC status.

Increased threats to large trees.
Additional exceptions to the limit on logging trees larger than 30 inches diameter have been included in the new strategy. Trees as large as 40 inches diameter could be logged outside of PAC and territory-designated habitat in “very limited instances” that have been defined in the strategy, including for the purpose of removing shade tolerant species to promote the growth of shade-intolerant species. Based on past experience, exceptions such as this are prone to manager abuse and it is unclear how extensive the practice will be.

These highly concerning and scientifically unsupported changes in spotted owl habitat management cannot be implemented without amending the existing forest plans. However, a Draft Supplemental Environmental Impact Statement (EIS) for the revision of the Sierra and Sequoia National Forest’s forest plans is expected to incorporate the new spotted owl conservation strategy and be released in the coming months. The Stanislaus National Forest has also stated its intent to propose amending their forest plan to fully implement the new spotted owl strategy in a project they plan to begin scoping on this summer. These pending EIS’s will require the agency to justify the proposed changes, define the effects the changes will have on the species, and respond to our concerns.

Trump Administration Proposes More Logging, Less Environmental Review, and Less Public Input

The U.S. Forest Service has released a proposed rule to overhaul the agency’s environmental analysis procedures under the National Environmental Policy Act (NEPA). The changes will dramatically curtail the role the public and science play in land management decisions on 193 million acres of national forest lands across the country.

These changes would create loopholes to increase the pace and scale of resource extraction, including logging and mining, all while limiting the scope of public awareness and input on proposed projects. The Forest Service has proposed several new categorical exclusions that would allow the agency to move project planning behind closed doors by cutting the public from the decision-making process.

The goal of NEPA is to foster better decisions to protect, restore, and enhance our environment and is based on three key principles: 1) transparency; 2) informed decision making; and 3) giving the public a voice. This is achieved through two key tools: public comment and requiring the Forest Service to “look before it leaps” by preparing environmental assessments (EA) and environmental impact statements (EIS). These documents provide agency decision makers, the public and outside experts with relevant information and require agencies to take a “hard look” at the potential environmental consequences of a proposed project before making decisions and taking actions.

The Forest Service’s proposed rule undermines these basic tenets by increasing the number and scope of “categorical exclusions” for nearly every type of land management action, and exempts those decisions from public comment. Only cursory public notice may occur.

To justify its proposed rule, the Forest Service argues that changes to NEPA are necessary to increase efficiency and increase the pace and scale of land management decisionmaking. However, the Forest Service itself has acknowledged that a lack of internal agency capacity and training, as well as an agency culture that rewards “moving out to move up” (or, agency turnover), leads to delays in planning and implementation. The proposed rule does not address this fundamental problem.

Proposed changes that we are very concerned about include:

Expands categorical exclusions. NEPA allows certain projects to be categorically excluded from detailed environmental review. In some cases, the public would only be notified of a proposed project, without an opportunity to review or comment on its environmental consequences. As a result, the federal courts will be the only way for the public to have their voice heard. The Forest Service also proposes to adopt any categorical exclusion created by any other federal agency as its own, without discussing the environmental effects or appropriateness of these potentially limitless exclusions.

Utilization of “determinations of NEPA adequacy.” This new proposed authority, based on similar Department of Interior authority, would allow the Forest Service to rely on its “experience” with past projects to authorize a proposed action of a similar nature without conducting site-specific environmental analysis. However, because the Forest Service rarely monitors the actual effects of its decisions, it is unlikely that the agency can rationally conclude that future projects will have no environmental impacts. Moreover, given the severely degraded condition of many of our national forests, it is arbitrary to suggest that past land management decisions have resulted in limited environmental impacts.

Embracescondition-based management. This authority allows the Forest Service to conduct land management actions, generally timber harvest, whenever the agency encounters a particular environmental condition, such as insect outbreaks or high fuel loads, on the ground.  Site-specific analysis would not be required. The agency would not be required to consider a range of alternatives to addressing the environmental condition, even though alternative development is the “heart” of the environmental analysis process.

A common theme across these proposed changes is to authorize nearly every land management action possible without detailed environmental analysis and public comment or administrative review.

We are working with groups across the nation to review and comment on these proposed rules. Comments are due by August 12, 2019. Individuals can submit comments through the public participation portal and additional information on the proposed rule can be found here.

Also see the note below regarding upcoming Forest Service webinars on the proposed rule.

Report from the Fire MOU Partnership Meeting - Spring 2019

The Fire MOU—co-authored by Sierra Forest Legacy and the U.S. Forest Service in the fall of 2015 to support expanded use of fire for ecological and other resource benefits—has grown to 37 member agencies and organizations throughout California. On April 5, over fifty members of the Fire MOU Partnership gathered at the Wildland Fire Training Center in McClellan, California for our annual “indoor” meeting to share and learn the latest from key fire and forest ecologists working in California and beyond. The following is a summary of the discussions and presentations.

Expanding Fire Restoration in California

The busy morning session included excellent presentations by Courtney Schultz, Director of the Public Lands Policy Group and Associate Professor Forest and Natural Resource Policy at Colorado State University, on her work and report focused on Barriers to Burning.

Following was Rob York, from UC Berkeley and Blodgett Research Forest, discussing Pyrosilviculture and integrating fire ecology, fire history and fire use into decisions about forest manipulations to meet management objectives.

Next up was Malcolm North, PSW and UC Davis researcher discussing fire and reforestation as part of his (and 24 other authors') examination of the failure of outdated reforestation strategies that ignore fire’s role in the forests of California. Known as the “Pines in Lines” paper, it has created a stir in the world of traditional silviculture and with those committed to highly flammable plantation forestry that fosters on-going fire suppression at the landscape scale.

Following Malcolm was Brandon Collins, PSW and UC Berkeley, discussing the role of mixed-severity fire in the Sierra Nevada and restoring fire in recently burned landscapes. Brandon is helping us think about using fire to deal with overly dense and uncharacteristic post-fire environments, and the need for ongoing fire maintenance.

Wrapping up was Jamie Lyderson, fire ecologist now working for CAL FIRE’s Fire and Resource Assessment Program (FRAP), speaking on the topic of Pyrodiversity. Jamie discussed the various components of Pyrodiversity—fire interval, season of occurrence, fire size, fire severity, fire behavior—and pyrodiversity links to biodiversity. The role of fire suppression, fire exclusion and climate change are key to understanding changes in forest structure and our ability to create structural heterogeneity with prescribed fire, or wildfire managed for multiple resource benefits.

All fire presenters then sat for panel discussion and a great Q&A session before moving to our Operational Smoke Management session in the afternoon.

The Smoke Management Strategy session in the afternoon was a three hour, structured discussion among air quality scientists, air regulators and the meeting members that explored and captured the thoughts of the participants, using a topic outline to focus the discussion and two excellent note-takers to capture the key points. The session was focused on the collaborative efforts of fire managers and air quality regulators to craft operational guidelines for a state-of-the-art smoke management strategy, working with federal (EPA) and state (CARB) and local air districts to advance the three pillars of the strategy—monitoring-modeling-messaging—for the expanding fire restoration program in California. On this front, SFL worked hard in 2018 to support a $2 million-dollar state budget line item to cover the costs associated with expanding monitoring equipment, training, maintenance and expanded modeling expertise plus coordinated fire and smoke messaging efforts throughout California.

California’s unique and productive partnership between air regulators and fire managers has resulted from the shared understanding that there is NO-NO FIRE option for California given our very fire-promoting climate and strongly fire-associated vegetation types throughout most of the state. Three California air districts (Butte, El Dorado, and Placer Counties) have joined the Fire MOU and the California Air Resources Board staff are actively engaged with fire managers to expand restorative burning and improve protection of public health. The Operational Guidelines for State-of-the-Art Smoke Management Implementation draft is the result of Lee Tarnay and Trent Procter from the Forest Service and Dar Mims and Michael Benjamin from the CARB sitting through many discussions over the past three years with agency and NGO partners, tackling tough issues such as the need to significantly expand burning and to protect the public health of our 40 million residents in California. The West is burning but California is leading the way in addressing “Living With Fire” and shared goals of public health protection in a collaborative, science-based Operational Guidelines for State-of-the-Art Smoke Management Implementation.

Download all of the presentations from the Fire MOU Partnership Meeting at the California Fire Science Consortium website, here.


Forest Service Hosts Webinars June 25 and July 12, 2019

On June 13, 2019 the USDA Forest Service published a proposed rule to revise its National Environmental Policy Act regulations (36 CFR 220). The Forest Service is hosting two information-sharing webinars for the public to learn about the changes in the proposed rule. The same content will be presented on each webinar; they also will be recorded and posted online for later viewing.

Webinar #1
Date: June 25, 2019 Time: 3:30-5:00pm (EDT)
Audio: 1-877-369-5243 or 1-617-668-3633
Access Code: 0524699##
Adobe Connect URL:

Webinar #2
Date: July 12, 2019 Time: 3:30-5:00pm (EDT)
Audio: 1-877-369-5243 or 1-617-668-3633
Access Code: 0849770##
Adobe Connect URL:

Both webinars will contain the same information. Additional webinars for the Tribal community will be held earlier in the day for each session. Information for the Tribal sessions can be found here.

More information is available here.

Annual Meeting of the Southern Sierra Prescribed Fire Council, November 6-7, 2019

SAVE THE DATE! Annual meeting of the Southern Sierra Prescribed Fire Council. The meeting on November 6 will be held at the Central Sierra Historical Museum in Shaver Lake. November 7 will be a field trip to see prescribed burning on Southern California Edison forest lands. More details to come soon on the SSPFC website.


Have a few minutes? Don't miss these news items, video shorts and links.

As California wildfire season looms, finding tree trimmers is a new problem. New York Times, May 23 2019.

Fighting fire with fire: Should California burn its forests to protect against catastrophe? Sacramento Bee, May 29, 2019.

The West has many wildfires, but too few prescribed burns, study finds. LA Times, May 29, 2019

Learn about the potential for soil carbon sequestration. Presentation by Luke Nave, researcher at Michigan State Biological Station and coordinator of the National Soil Carbon Network.

Fire season is coming. Learn the proper way to fit a NIOSH N95 adult mask. Find more like this at the Fire Learning Network.


Spotlight on Species: Gray Wolf (Canis lupus)

Gray Wolf Yellowstone National Park

Image above: Gray Wolf, Yellowstone National Park. Photo by NPS.

The gray wolf (Canis lupus) was once one of the world’s most widely distributed mammals, with a circumpolar presence in the northern hemisphere ranging from northern Mexico in Central and North America, in Ireland and the British Isles, throughout Europe, in Africa and India north of the 15th parallel, and Asia, the Arabian peninsula, and Japan. The wolf’s relationship with human beings is long and complicated, and few mammals have been the subject of as many stories, myths, and legends as the gray wolf. In art and literature they have been long depicted as cunning, vicious, and evil—despite the fact that all of our beloved domestic dogs are descended from wolves. 

The gray wolf was first named Canis lupus by Swedish botanist Carl Linnaeus in 1758, and today there are at least 38 named subspecies of the gray wolf worldwide. Between 1967 and 1978, the gray wolf in North America had been classified into six separate subspecies. Today, for management purposes and because of the present day taxonomic uncertainty, all subspecies in the U.S. are subsumed under C. lupus, with the exception of the Mexican wolf, subspecies C. lupus baileyii. The taxonomy for wolves continues to be unsettled and complicated, as improved DNA analysis opens up new insights regarding wolf and coyote hybridization, and the effects of multiple introgression hybridization from reintroductions of subspecies genes from populations in the north, south, and eastern regions of the continent.  

Adult gray wolves range in size from 18 to 80 kg (40 to 175 lbs), depending on sex, environment, and genetic differences. Their coloration is usually a grizzled gray, a mix of gray, black, rust, and cream, but individuals may be all black or all white. Some wolves in British Columbia even have a pinkish hue, thought to result from high levels of salmon consumption. In North America, wolves are primarily predators of medium and large mammals, such as moose, elk, white-tailed deer, mule deer, caribou, muskox, bison, and beaver, but they also prey upon domestic livestock, pets, and smaller mammals when the opportunity arises. Wolf attacks on humans are rare, unless the wolf is rabid or starving. Attacks by healthy, wild wolves are unlikely under normal circumstances, and some attacks have been associated with habituation with humans as a food source.

Gray wolves are highly territorial, social animals and group hunters, normally living in packs of seven or fewer family members consisting of a breeding pair, their pups from the current year, offspring from previous years that have not yet dispersed, and occasionally another non-relative. However, packs with as many as 37 members have been documented in Yellowstone National Park since reintroduction, and packs as large as 27 have been reported elsewhere historically. Litters are generally 5 to 6 pups born from early April into May. Offspring usually remain with their parents for 10–54 months before dispersing. In general, by the age of 3 years, most wolves will have dispersed from their natal pack to locate social openings in existing packs or find a mate and form a new pack.

Packs live within territories that they defend from other wolves. Wolves can and do kill rival pack members, including their pups, although they never eat their own kind. Wolves howl to communicate with each other and to signal rival packs. Territory sizes range from approximately 20 to 215 square miles, depending on available prey and seasonal prey movements, but in the Northern Rockies territories are much larger, typically varying from 200-400 square miles. Single wolves that have been collared with GPS satellite tracking devices have been known to cover 6,000 miles or more.  

Wolves are keystone predator species, and have shaped the coevolution of species that share their habitats. They are thus thought to be essential to keeping ecosystems in balance, as Aldo Leopold first articulated in his 1949 essay “Think Like a Mountain” (in A Sand County Almanac).

Wolves are thought to be very resilient and adaptable in response to environmental changes and stress, and if humans can learn to accept the presence of wolves, there is a good chance that they will once again become widespread. Wolf habitat is non-specific, as wolves are able to occupy virtually any habitat where there is sufficient prey and protection from human persecution. Wolves are thought to have once been the most widespread predatory mammal on the planet.  

Due to human population expansion, bounty hunting, and other depredations on the wolf, by the early 1900s wolves had become rare or had been extirpated from most of their range in the conterminous United States, except in northeastern Minnesota. Globally, they were also extirpated in Europe, southeast China, and Indochina. Gray wolves remained widespread in Alaska and Canada. In 1915, the federal government began publicly funding trapping, poisoning, and shooting of wolves to protect livestock and to increase deer and elk herds to benefit hunters. 

Prior to the enactment of the Endangered Species Act (ESA) in 1973, wolves were afforded some protection under the ESA’s predecessors, the Endangered Species Preservation Act of 1966 and the Endangered Species Conservation Act of 1969. The gray wolf was listed in 1974 as endangered throughout the lower 48 states. The Act was amended in 1978 to include subspecies and “distinct population segments” of species, subsequently all subspecies of gray wolves in the lower 48 states were listed as either endangered or threatened.

It took another 20 years before a recovery plan and environmental impact statement that included reintroduction was finalized. Wolf reintroduction has always been contentious. The idea was first brought to Congress in 1966 by biologists concerned about resource damage from abnormally high numbers of elk in Yellowstone National Park, where no wolves had been seen since the last wolf was killed there in 1926. Elk had become so abundant that, in order to keep the herds healthy and restore damaged plant communities, wildlife managers had resorted to culling elk herds. This practice was halted in the 1960s, in response to outcry from hunters and affiliated businesses in Wyoming. As a result, elk populations again soared. 

The final gray wolf recovery plans required reintroduction of gray wolves in two of the three recovery regions (northern Rocky Mountains and southwestern United States) while recovery in the third (eastern United States) would depend upon natural recolonization and population growth. The environmental impact statements included a provision under section 10 (j) of the 1982 amendment of the ESA to classify the introduced populations as “non-essential, experimental.” This designation afforded less protection and would permit killing of wolves outside federally protected public lands. This compromise was necessary to obtain acceptance of wolf reintroduction in the regions where politically powerful livestock ranching and elk hunting interests hold sway.     

Wolves arriving in Yellowstone by truck 1995

Image above: The first wolves from Canada arriving by truck in 1995, Yellowstone National Park. Photo by NPS.

In 1995 and 1996, the US Fish and Wildlife Service (FWS) reintroduced a total of 66 wolves from southwestern Canada to remote public lands in wilderness areas in central Idaho and Yellowstone National Park. Wolves soon became established throughout central Idaho and the Greater Yellowstone Area, demonstrating the wolf’s adaptability and resilience when no longer subject to publicly funded extermination campaigns.

Once wolves began to disperse outside of the park, conflicts with ranchers were inevitable. While the majority of wolf kills are wildlife, when given the opportunity wolves will kill livestock and pets, including livestock guard dogs. However, livestock losses are a known part of the cost of doing business in the ranching industry, with losses from other causes numbering in the tens of thousands each year compared to the approximate 1 percent of loss from predation by wild predators.  

To offset  losses, Defenders of Wildlife stepped up to provide a compensation fund for ranchers with verifiable livestock kills from wolves. The program paid out $1.3 million to livestock producers in Montana, Idaho, and Wyoming from 1987-2009. Defenders of Wildlife continues to provide grants, in-kind donations, education in non-lethal methods for discouraging wolves, and other types of support to promote coexistence with wolves. Compensation programs for livestock losses are today funded by the states, with federal grant funds providing support for non-lethal wolf control methods and livestock management techniques that minimize wolf proximity to livestock during vulnerable times, such as calving. Additional funds have been raised by non-profit groups to buy out available federal grazing leases in the proximity of Yellowstone National Park.  

The criteria for recovery, or delisting criteria for the gray wolf determined in the recovery plans created for each distinct population segment, were established arbitrarily and were not scientifically rigorous. The wolf’s successful and rapid population increases and establishment in new areas is nevertheless a real success story—despite ongoing harrassment from humans—and the wolves appeared to have exceeded the minimum requirements for recovery in the Northern Rocky Mountains and the Western Great Lakes regions. By 2000, the movement to classify the wolf as “recovered” from endangerment or threatened status was in full swing, and FWS began the process of delisting, downlisting, and reclassifying wolf distinct population segments (DPS) across the US.

This was met with immediate court challenges from the environmental community, triggering a cycle of court battles that continue to this day. In response to losses in court, wolf opponents put pressure on Montana’s vulnerable Democratic senator, John Tester. Tester then authored a bill that was attached as a rider to the must-pass 2011 appropriations bill, and that mandated the delisting of the wolf in Montana and Idaho, thereby breaking up the DPS. (Wyoming was not included, since the state was openly hostile to wolf reintroduction, and even state wildlife managers could not provide a credible plan to provide adequate protection for wolves). The bill also stipulated that the change could not be challenged in court. President Obama signed the bill. This was the first time that Congress had enacted a law to override the Endangered Species Act, and the first time that delisting was not based on current science. The same tactic was tried again in 2015, this time the bill would lift protection for wolves in Wyoming and the Great Lakes region. This time, however, the rider was blocked by a coalition led by California’s Senator Barbara Boxer, and Obama did not compromise.

Nevertheless, the Wyoming exception ended in 2017, when an appeal court issued a final mandate delisting wolves in Wyoming, despite the state’s recalcitrance towards implementing protective measures for wolves outside of the park. With management under state authority, wolves in unprotected areas (i.e ., outside of  national parks) can be shot on sight if they are a nuisance, with no permit and no game limits. To date, at least 3,500 wolves have been killed in the Northern Rockies region since delisting;  many wolves  collared in Yellowstone NP were among the dead.

In November 2018, the U.S. House of Representatives passed another bill (HR 6784), that would mandate delisting the wolf throughout the continent (excepting the Mexican gray wolf), which remains highly endangered in an environment abounding with threats). The bill has not been passed by the Senate.

Map of current ESA status for gray wolf Mar 2019

Figure above: Current legal status of C. lupus under the ESA. From Federal Register, March 15, 2019, p. 5696. The FWS is currently proposing to remove these designations, except for the Mexican wolf.

For now, wolves outside of the delisted Northern Rocky Mountain distinct population segment remain fully protected under the ESA as endangered species. In Washington and California, the wolf is listed under the states' ESAs as well. It is explicitly unlawful to kill or intentionally harm gray wolves under these statutes, regardless of the federal status.  

The story of wolf conservation in the years since the enactment of the Endangered Species Act is one for the historians. Several books have been written about the reintroduction and the conflicts that ensued between wolf proponents and opponents. Wolves continue to be shot and killed with impunity. The motto “shoot, shovel, and shut up” in cattle country is too often embraced where wolf reestablishment is vigorously opposed. The single greatest cause of wolf mortality today is the same as it was a century ago: humans killing wolves. You can read a summary timeline of the history thanks to EarthJustice, here, and a summary from the Center for Biological Diversity, here. Despite the demoralizing cruelty displayed by our own species, the wolf is recovering, and it is thought that approximately 5,000 to 6,000 wolves are alive in the lower contiguous states, and they continue to establish in new areas. There are also an estimated 65,000 wolves across all of Canada and Alaska. We now must turn to the latest development, wolves in California, and the proposal by the Trump administration’s FWS to delist the gray wolf across the entire United States (excepting the Mexican wolf).

The Gray Wolf in California

The gray wolf is returning to California after its disappearance in the 1920s. Only two museum records actually document the historical presence of wolves in California. One specimen was collected in 1922 in San Bernardino County in southeastern California, and experts believe it is most likely the Mexican wolf subspecies, C. lupus baileyi.  The other specimen was from 1924, in Lassen County, and was old and emaciated. All other information is anecdotal, but suggest that wolves were widely distributed in California, particularly in the northern part of the state in the Klamath Mountains, Sierra Nevada, Modoc Plateau and Cascade Range.

California is well within documented dispersal distances from extant wolves that have established packs in Oregon, Washington, and Idaho. On December 28, 2011, a male collared wolf born into the Imnaha Pack in northeast Oregon in 2009, OR-7, crossed over the California border just north of Dorris in Siskiyou County. OR-7 spent most of a year in California, in mountain habitats west of Lake Almanor and throughout northeastern California, including the Sacramento Valley near Redding and Red Bluff. He eventually went back to Oregon, where he found a mate and founded the Rogue Pack.

Since then, two wolf packs have been documented in California, the Shasta and the Lassen packs, and four individual collared wolves have been detected with GPS. In 2015 the first pair of breeding wolves were discovered in eastern Siskiyou County. Named the Shasta Pack, the pair had a litter of five pups in August, 2015. Genetic testing revealed that the breeding pair were both descended from the same Oregon pack that produced OR-7. There have been no verified detections of the pack since late 2015, but one of the male offspring was detected in northwestern Nevada a year later in November 2016. The pack appears to be no longer in existence.

The Lassen Pack is the only currently known wolf pack in California. The female was first seen in 2015. By 2016, it appeared that she had found a mate. The male is descended from the Rogue Pack, as determined genetically from scat, and the female is thought to be dispersed from the Rocky Mountain wolf population. In June 2017, CDFW biologists were able to locate the female and outfit her with a GPS collar, and are now regularly monitoring her whereabouts. The pair had at least four pups in 2017 and five pups in 2018. The pack may have at least five members today, although an uncollared female yearling was found dead in Lassen County in September 2018.

Approx. area of gray wolf Apr 2019Image left: Approximate location of Lassen Pack wolf activity as of April, 2019 (yellow). California Department of Fish and Wildlife.

Gray wolves prefer to hunt ungulate species, primarily elk. There are three species of elk in California. While two of the three subspecies—Tule elk and Roosevelt elk—appear to be making a  comeback after decades of stewardship by state wildlife biologists, the Rocky Mountain elk that occur in the northeast part of the state are not increasing in numbers. Mule and black-tailed deer, the secondary prey species, have been in a long period of decline in the state, due to loss of habitat from agriculture and other types of human development, forestry practices that favor conifers over early successional habitats needed by deer, fire suppression, and plantation forestry. Thus it is unlikely that wolves will establish in densities or as successfully here as they have in the Greater Yellowstone Region, the Great Lakes region, or further north.

California Department of Fish and Wildlife finalized the state’s management plan for the Gray Wolf in 2016. You can download the two volumes of this document here.

Gray wolf delisting proposal 2019

On March 15, 2019, the FWS again proposed delisting the gray wolf in the entire 48 contiguous states, excepting the Mexican wolf that will remain endangered. The agency based its proposal on the modest recovery criteria that originated as a compromise to anti-wolf interests. The comment deadline on the proposal has been extended to July 15, 2019. All the associated documents can be accessed here.

Further reading:

Gray Wolf Biological Report (FWS 2018).

Blakeslee, Nate. 2017. American Wolf:  A True Story of Survival and Obsession in the West.  Crown Publ. New York. 300p.

Lopez, Barry. 1978. Of Wolves and Men.  Charles Scribner Publ. New York. 309p.

Thinking like a mountain by Aldo Leopold  “We reached the old wolf in time to watch a fierce green fire dying in her eyes….”

The Fable of the Wolf award-winning video short

Trail camera captures images of Lassen Pack pups, 2017

History of endangered species protection in the U.S.

EarthJustice wolves in danger timeline

Listen to a pack of wolves howling in Yellowstone Park, recording by Jennifer Jerrett as part of a collaborative project with the Yellowstone National Park Sound Library.



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